WellCare, Tenet Have More Than Probes in Common

Analysts feel baffled, to say the least.

"The details of Bolton's accusation are unknown, given the file is under seal, but what has come to light about the circumstances of the complaint is, in our opinion, bizarre," Credit Suisse analyst Gregory Nersessian wrote earlier this month. "If Bolton was aware of fraud at the time of this presentation (eight days before the raid and nine days before his whistleblower suit was filed), why did he participate on WellCare's behalf?"

Regardless, Nersessian added, "If Bolton's case is related to the investigation ... his background would suggest that there is substantial basis for regulatory involvement."

Bolton's credentials do look impressive. He is a certified fraud examiner and compliance professional who has served as an adjunct faculty member in the criminal justice department at Rochester Institute of Technology. Moreover, he has 16 years of investigation experience, with most of that focused on the health care arena.

Knowing all of this, WellCare investors must now ask themselves a tough question: Is Bolton embracing the same philosophy that he adopted at WellCare, when running its special investigations unit, now that he's pursuing the company instead?

If so, two slides from his recent presentation could prove haunting. In one, he stresses the importance of building strong cases that can go all the way to trial and win. In another -- possibly suggesting the power of his own complaint -- he says quite simply, there are "too many cases to work bad ones."

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